Information quality guidelines

The Consumer Financial Protection Bureau (Bureau) Information Quality Guidelines are issued in accordance with the provisions of the Treasury and General Government Appropriations Act for Fiscal Year 2001, Pub. L. No. 106-554 (the “Act”), and OMB government-wide guidance.

The administrative correction mechanisms outlined in the guidelines apply to information disseminated by the Bureau on or after the date of publication, regardless of when the information was first disseminated. These guidelines provide policy and procedural guidance to Bureau staff and inform the public about Bureau policies and procedures for making corrections to published information.

Information Quality and Peer Review Disclaimer: After review of the information disseminated by Bureau, the Bureau does not believe that it currently produces or sponsors the distribution of influential scientific, financial, or statistical information within the definitions promulgated by OMB, and does not at this time have material to post in accordance with OMB’s Information Quality Bulletin for Peer Review.

The Bureau disseminates a variety of information to the public, including press releases, publications, and special technical reports. Section 515 of the Act requires federal agencies to issue guidelines ensuring and maximizing the quality, utility, objectivity, and integrity of disseminated information and to provide the public with an administrative means for correction of information disseminated by the Bureau.

Information quality correspondence

At this time, we’ve received two information quality
correction requests:

The first request
was submitted by the Community Financial Services Association of
America on June 20, 2013, and we responded
on August 19, 2013. CFSA filed an appeal of the Bureau’s response
on Sep. 18, 2013, which the Bureau denied on Nov. 18, 2013.

Information quality guidelines

The Bureau strives to ensure and maximize the quality, objectivity, utility, and integrity of the information that it disseminates to the public. The Bureau strives to incorporate information quality criteria into its information dissemination practices, and ensures the quality of information the agency disseminates in accordance with the standards set forth in these Guidelines. The Bureau is committed to integrating the principle of information quality into its development of information, including the creation, collection, maintenance, and dissemination of such information. The Bureau will comply with all legal and policy rules, regulations, directives, and guidance governing any phase of the process. High quality information represents a performance goal for organizational components of the Bureau who are charged with disseminating information.

To ensure and maximize quality information, the standards should focus on the three underlying requirements for quality: utility, objectivity, and integrity of information.

Utility: In assessing the usefulness of information disseminated to the public, the Bureau will consider how the public will use the information. When transparency of information is relevant to an assessment of the public’s perception of its usefulness, the Bureau will address transparency – the clear, obvious, and precise nature of the data or analysis – when developing and reviewing information.

Objectivity: The Bureau will consider whether disseminated information is accurate, clear, complete, and unbiased both in presentation and substance. Information will be presented within its proper context. Where appropriate, data will be accompanied by full, accurate, and transparent documentation, and will disclose error sources affecting its quality. Analytic results will be generated using sound statistical and research methods.

Integrity: The Bureau will protect information from unauthorized access or revision, to prevent corruption or falsification of information. The Bureau will comply with government-wide security requirements when disseminating information.

The Bureau will strive to ensure that statistical and financial data disseminated by the Bureau is capable of being substantially reproduced by an independent evaluator, subject to some degree of imprecision. The Bureau will also provide the sources, methods, procedures, references, and assumptions employed to create information disseminated by the Bureau.

When used regarding financial or statistical information, a characterization of “influential” generally means the Bureau determines that dissemination of the information will have or does have a clear and substantial impact on important public policies or important private sector decisions. Organizational components of the Bureau shall develop appropriate definitions of what constitutes “influential” information as they develop processes for dissemination. When information is determined by an organization component to be “influential,” an added level of scrutiny will be applied, including an assurance that the information is reproducible.

Purpose

The Bureau has drafted the following guidelines to promulgate its quality standards and formalize its correction mechanism. The policies and procedures strive to ensure that the quality of information and data released to the public is accurate and appropriate and meets the Bureau’s internal definitions of utility, objectivity, and integrity.

This guidance should be used to ensure and maximize the quality of information disseminated by the Bureau. The Bureau’s guidelines are based on the OMB guidelines. The guidelines are not intended to be legally binding regulations or mandates. They are not legally enforceable and do not create any legal rights or impose any legally binding requirements or obligations on the Bureau or the public. Nothing in these guidelines affects any otherwise available judicial review of agency action.

Scope

The Bureau guidelines are effective upon publication. The guidelines cover information disseminated on or after publication of the guidelines, regardless of when the information was first disseminated.

Organizational components should use these guidelines to develop processes for disseminating quality information. The guidelines apply to information disseminated to the public in any medium, including textual, graphic, narrative, numerical, or audiovisual forms. The guidelines apply to information that the Bureau posts on the internet. The guidelines also apply to Bureau-sponsored distribution of information – that is, any information distributed by a third party at the direction of the Bureau or information the Bureau has the authority to review and approve prior to release. The guidelines do not extend to Bureau interpretations of data and information.

The guidelines do not override other compelling interests such as privacy, trade secrets, intellectual property, and other confidentiality protections. The guidelines do not apply to hyperlinks to information disseminated by others. The guidelines do not apply to opinions where the Bureau’s presentation makes it clear that the material is an opinion or the Bureau’s views rather than fact. In addition, the guidelines do not apply to information disseminated in the following contexts:

Dissemination of information limited to government employees or agency contractors or grantees;

Dissemination of information intended to be limited to intra-or inter-agency use or sharing of government information;

Response to requests for agency records under the Freedom of Information Act, or other similar laws.

Process

Information review

Information quality is integral to every step of the development of information, from its creation through its collection, maintenance, and dissemination. Organizational components of Bureau are expected to develop processes for reviewing the quality, including the objectivity, utility, and integrity, of information before it is disseminated. The processes should substantiate the quality of the information disseminated through documentation or other means appropriate to the information.

The Bureau will disseminate information that meets high standards as confirmed by stringent internal review and approval processes. The Bureau will produce information products that are presented in an unbiased, clear, complete, and well-documented manner. It will utilize highly reliable review sources for corroboration of information, and will seek public comment as appropriate. Specialized surveys and peer reviews will utilize methodologies that are consistent with generally accepted industry standards for all aspects of survey design and implementation. The Bureau will make both original and supporting data and the source of the data available to the public when appropriate. The Bureau will utilize transparent methods consistent with its obligation to protect proprietary or confidential information. The Bureau will subject all information to editing and review.

The Bureau will regularly review information output products to ensure their current utility to the public.

Information collection

Bureau adheres to OMB’s Paperwork Reduction Act (PRA) clearance process to improve the quality of information that the Bureau collects and disseminates to the public. The PRA requires the Bureau to demonstrate the “practical utility” of a proposed collection of information that Bureau plans to disseminate. Bureau will also demonstrate in PRA clearance submissions to OMB that the proposed collection of information will result in information that will be collected, maintained, and used in a way consistent with the OMB and Bureau information quality guidelines.

Administrative complaint mechanism

Any individual who believes that information disseminated by the Bureau does not comply with OMB or Bureau guidelines may seek correction of the information by filing a “Section 515 Complaint” with the Bureau. The process for filing a complaint is intended to be flexible, appropriate to the nature and timeliness of the disseminated information, and incorporated into the Bureaus’ information resources management and administrative practices.

Complaint process. A complaint may be submitted by mail, personal delivery, electronic mail, or fax using the following contact information:

A statement that the individual is submitting a complaint pursuant to section 515 of Public Law 106-554;

Contact information, including name, mailing address, telephone and email address, and the name of any organization with which the individual is affiliated;

Identification and description of the information or data the individual is seeking to have corrected, including, for example, the number or title of the document(s) in which the information appears, the date of release, or the URL of the web page on which the information was disseminated by the Bureau;

A statement of the reasons for believing that the information or data is in error, including a statement of what the individual believes the correct information or data to be and how the information should be corrected;

A statement of how the disseminated information affects the individual.

Privacy policy: The Bureau is authorized to collect the information provided under Section 515, 44 U.S.C. § 3516. The information is necessary to process any request for correction of information disseminated by Bureau. An individual is not required to furnish the information, but failure to do so may prevent the request for correction from being processed. The information provided will rarely be used for any purpose other than to process and respond to a request; however, the Bureau may disclose information to other federal entities such as Congress or the Department of Justice if required to do so by federal law.

The individual filing the complaint has the responsibility to clearly present the basis for the section 515 complaint. The Bureau may determine that the complaint does not meet the threshold requirements for processing, either because required elements are not addressed or because the allegations are too vague for the Bureau to take action. The burden of proof falls on the individual filing the complaint to show both that he or she is an affected party and that the information needs to be changed. An individual whose complaint is rejected may file an appeal in accordance with the procedures set forth below.

The Bureau will respond to a complaint and/or request for correction in writing within 60 days of receipt. If additional time beyond 60 days is required, the Bureau will notify the petitioner. The complaints manager will review the complaint for formal sufficiency and identify the appropriate organization for evaluating and responding to each complaint. The organizational component responsible for disseminating the information will determine whether an adequate case has been presented to require correction of the information and or data identified in the complaint.

Administrative appeal process

If a petitioner is not satisfied with the Bureau response to a Section 515 complaint, the petitioner may administratively appeal the initial decision. Any such appeal must be submitted to the organization component that disseminated the information within 30 calendar days of receipt of the initial decision. The appeal must identify the original request for correction and describe how the Bureau response failed to resolve the request. The appeal will be evaluated by a Bureau official other than the initial reviewer who has organizational knowledge of the information sought to be corrected. Bureau will respond to the appeal in writing within 60 calendar days of receipt. If the response will require an extended period for review, the Bureau will notify the petitioner.

Requests concerning information on which the Bureau sought public comments

The correction and appeal process set forth in these guidelines does not apply upon first publication to information disseminated by the Bureau through a comprehensive public comment process – e.g., Federal Register notices of proposed rulemakings, regulatory analyses, and requests for comments on information collections subject to the Paperwork Reduction Act. In most cases, comments concerning the quality of the disseminated information can be addressed through these procedures, such as by responding to a request for correction of the information in the preamble to a final rule. In unusual circumstances, the Bureau may determine that earlier consideration of such comments in accordance with these guidelines would be appropriate. For example, the procedures set forth in these guidelines should be used if the commenter has shown a reasonable likelihood of suffering actual harm if the comment is not resolved before issuance of the final action and the Bureau determines that resolving the matter pursuant to these guidelines will not unduly delay the final action.

The Bureau will regularly review information products that have been disseminated to the public to ensure that they continue to meet high standards of quality, including objectivity, utility, and integrity.

Responsibilities

The Chief Information Officer will:

Provide management and oversight to the Bureau-wide implementation of the guidelines

Develop and issue final Bureau information quality guidelines and post them on the Bureau website

Report to the Director of OMB on the number of and nature of complaints regarding compliance with the guidelines for the quality of disseminated information and how such complaints were resolved

Organizational components will:

Designate a point of contact for compliance with the information quality processes within their organization

Develop, if necessary, information quality standards for ensuring and maximizing quality, objectivity, utility, and integrity of information, including statistical information, consistent with these guidelines

Designate individual(s) responsible for reviewing and deciding the initial review of complaints and individual(s) responsible for reviewing and deciding appeals

Reporting requirements

Bureau will consider public comments received in response to publication of these draft guidelines, and submit revised guidelines to OMB for review. Bureau will post notice of the availability of final guidelines in the Federal Register and post the final guidelines approved by OMB on its website. Bureau will provide annual reports to OMB indicating the number and nature of complaints received concerning agency compliance and how such complaints were resolved.